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Distributed Generation: Doomed by Deployment Details?
Exemptions? But NRDC also had one of the few quibbles about the report. The group worries that the CEC's recommendation to expand categorical exemption from CEQA for certain types of projects will come to pass. The report leaves open how the exemption would be expanded, calling for the CEC's staff to develop eligibility criteria.
"It seems to express the intent that DG equipment should be meeting the same kinds of emissions standards as large central stations-you know, 5 [parts per million, for nitrogen oxide] or better-and that's going to be quite difficult when you're dealing with these little units," says Lindh. "You don't have the economy of scale to put on selective catalytic reduction, for instance. I think if the [CARB] takes as its marching orders that it has to standardize a level around 5 ppm, then I think fossil DG is dead in this state."
Interestingly, while the CEQA report states that most DG equipment manufacturers also are opposed to setting emission standards at the same levels as central power stations, Capstone Turbine Corp. is an exception. The manufacturer of microturbine systems supports the idea in principle.
"Capstone is very supportive of the goal that's seen in the legislation … that … over a time frame to be defined by the regulators, the emissions of distributed generation shall align with the emissions of central power plants," says Kevin Duggan, manager of environmental and regulatory issues at Capstone.
But, says Duggan, Capstone can't meet those limits right now, so a "reasonable time frame" needs to be set. In working to meet the emissions limits, the company is operating on the premise that the public will demand an equal playing field for power generators, whatever their size. "[W]e believe that to become an acceptable mainstream product, we have to live by the rules of the industry-no exceptions, no special deals. If we want to be a player, we have to be playing on the same field as the rest of the electricity industry."
California isn't the only state grappling with emissions standards for DG. In November the Texas Natural Resource Conservation Commission released a draft of its "Air Quality Standard Permit for Small Electric Generating Units." The draft states the TNRCC's belief that distributed generation must adhere to the emissions standards of central generating power stations.
Of greater import to Capstone is another key policy issue: that the DG products themselves should be permitted rather than the sites. That, says Duggan, is crucial to DG's proliferation because the very concept of DG is based on lots of small units producing power, as opposed to a few large generating stations. Certify the technology by verifying that its emissions levels meet a certain standard, and then let it be installed without being site-specific.
Thousands upon thousands of DG installations out there, Duggan says, would make individual siting virtually impossible. "It's just going to be an overwhelming burden on the bureaucracy to actually permit site by site. … I think that's the other really important thing that both Texas and California have picked up on and